Provision for cycling in this scheme is not compatible with the Mayor’s Cycling Vision, your own aims for casualty reduction or a twenty-year design life. On the design life in particular we believe that the lack of coherent cycle planning in this design means if built as planned it would not last twenty years without significant and costly alterations.

Two metre wide cycle lanes are welcome but not if they are discontinuous and disappear at junctions and bus-stops where they are most needed.

Protected lanes should be provided given the levels of traffic on these roads and you need to make use of bus stop bypasses as seen on the Superhighway 2 extension and trialled at the Transport Research Laboratory for TfL.

Off-street parking and loading bays may help remove these uses from the carriageway but placing them on the inside of a cycle lane creates conflict. Design should be developed that places cycle lanes inside of the bays instead.

Two-way cycling on one-way streets is welcome but entry and exit alignments not good enough quality for Lime Grove or Pennard Road and Richford Street in particular is ignored and left no-entry despite regular use. As we stated a year ago, we want to see two-way cycling on many more streets in the borough, and support further examination of suggestions that may come in during this consultation.

There also remain levels of pavement cycling by both children accessing local schools and adults that show provision on these major roads is not subjectively safe. Like with two-way cycling we see providing safe space on streets as an intervention that helps reduce this behaviour.

The junction of Goldhawk Road and Hammersmith Grove has several failings chief of which is the removal of a cycle lane heading Westbound whilst widening both Westbound lanes.

There is potential in this area to trial cyclist phases and low-level lights.

Where innovations necessary are yet to be approved please arrange this within your existing phased delivery plan.

Should it be necessary we would support a further consultation if it helps enable improvements to be delivered. Perhaps a forum such as that held annually by the City of London to help engage those who cycle in their area could help your plans come closer to the expectations of cyclists in your borough. More open and regular discussions ahead of consultations would be of benefit to us all.

As it is unclear where cycle parking is to be provided we would suggest the following priorities

Goldhawk Road Station and associated bus garage

Shepherds Bush Market itself

Shepherds Bush Station

Residents on affected streets, especially Lime Grove and the fashion college

Cyclehoop facilities could be used on posts throughout the scheme

Bush Theatre

We are concerned that this scheme has made insufficient account both of the needs of current cyclists and of those future incremental journeys called for both in local policies and in the Mayor’s Cycling Vision. We are glad to see a continued pursuit of two way cycling on roads that are otherwise one-way and additionally suggest this for Richford Street, however in all cases we feel side street approaches are not of sufficient quality to work at their best for pedestrians and local residents in particular. We would welcome a wider effort to enable two way cycling on one way streets as we know that this can be of particular annoyance to those who cycle on these streets especially when in close proximity to a gyratory like here in Shepherds Bush.

A key feature of your design are the raised parking and loading bays to be accessed in all cases over the advisory cycle lane running adjacent. There are two risks with this design we are concerned with:

First, there is the risk from drivers entering and exiting these bays. Given that the road will be a single lane in each direction any drivers parking a vehicle will feel pressure to park from vehicles behind them. Whilst the cycle lane between the running lane and the parking will be two meters wide cyclists will be either in or passing between blind spots whilst passing stationary traffic. It may well be unapparent to them that vehicles are indicating to park. All of this will cause conflict, perceived danger that discourages cycling and a risk of collision as vehicles enter the bays. Similarly visibility may cause issues in leaving the bays over the cycle lane again. This may well be compounded by vehicles coming from the west parking against flow to avoid the gyratory, especially as they are unable to execute a U-turn any closer to the east than at Holland Park Roundabout.

Second, there is the risk from vehicle doors being opened onto the cycle lane. This can be mitigated somewhat with widths, but given the unusual nature of the parking and the seeming increase in vehicle widths it is unlikely that width alone can eliminate the conflict. We note from recent FOI requests that cyclist accidents in Goldhawk and Uxbridge Roads appear to be predominantly caused by car doors being opened into the path of cyclists. We note also that there has been a sad trend of deaths in such cases such as James Darby and Sam Hardingand would urge you to eliminate such conflicts at the earliest opportunity in high-risk locations such as these. London has the highest rate of these incidents as factor of all road accidents in the UK (355 of the 597 reported in UK and 2% of reported incidents as per RAS50012 in the 2012 statistics as against 0-1% elsewhere). Placing cyclists into the door zone is not acceptable and we expect to see good widths here that prevent that from happening at the very least.

A configuration that had a cycle lane running on the inside of such bays would avoid these conflicts if adequately designed. There would be a need for deliveries to cross the lane, but that is an aspect that King Street already sees. Timing of deliveries should also be considered to reduce that conflict as far as possible. One of your aims is casualty reduction and we are keen that you place some focus on cyclists and their safety; the better position of other modes means that cyclists are now 39% of KSIs in the borough in 2012 as opposed to 17% in 2005. Indeed, in absolute terms more people on bikes than on foot were involved in a KSI in the borough last year. We welcome a continuing discussion on this trend separate to this consultation as we feel that it is not in keeping with growth in cycling either nationally or locally. We do not want the fear of danger encountered whilst cycling to cause growth in cycling nationally or locally to stop or slow down.

Another key feature in your plan is the relocation and reconfiguration of bus stops. We think this is least successful near Goldhawk Road Underground station but it presents a problem throughout the design. We would favour the incorporation of Bus Stop Bypass arrangements as trialled by TfL at the Transport Research Laboratory. It may be that this is not immediately feasible, but we feel that given that this is a design for 20 years it should be capable of handling them if implemented in the latter phases in 2015 as outlined in the consultation.

For the stops before and after Goldhawk Road there is the added complication that there is a bus garage for London United on Wells Road. In particular for buses on route 94 this means buses entering and leaving service at nearby stops and changes of driver. As such a bus stop with space for only two buses may be inadequate. Additionally this means that there are several movements through the Goldhawk Road/Wells Road junction of buses entering and leaving service. We note that you have not provided any signals to support these movements unlike the arrangement at Stamford Brook bus garage. We think a further stage of design is necessary to handle this area safely and we think that again, protected space for cycling away from the areas of conflict would help your design be successful.

We ask that you make significant changes to these plans that allow you to incorporate protected space for cycling in continuous routes that deal with the conflict inherent in the parking, junctions and bus stops that your current design fails to handle. You are retaining cycle lanes where bus lanes are going which is positive, but interrupted advisory cycle lanes are rather weak provision, which rely on the good positioning of other vehicles to permit cyclists to make use of the space allocated. In addition to the interruptions noted already we see that at junctions and at crossings the cycle lanes disappear, exactly the locations where safe space for cycling would make the most difference. We are particularly concerned that the approaches taken on Goldhawk Road and Uxbridge Road are unable to provide either a sufficient step-change to conditions for cycling immediately or support future changes during the 20-year design life you envisage. Whilst it is plausible that some funding may become available over that time the decisions made here of providing parking and loading accessed over the cycle lane and planting new trees will both present potentially insurmountable obstacles to improving this route.

The rest of our feedback will take you through these issues on a road-by-road basis, mirroring your plans (so Pennard Road will be considered in Uxbridge Road and Goldhawk Road approaches only):

We welcome the introduction of two-way cycling to this street. We will consider the features in the direction of travel for a cyclist following this contraflow (from Uxbridge Road to Goldhawk Road).

The entry into Lime Grove from Uxbridge road is front a box, which is immediately before a bus stop on either side of the road and opposite the side of the junction which vehicles, will use to exit Lime Grove. This does not seem to work well, and in cases where a bus is stopped nearby in either stop location, and a vehicle is leaving Lime Grove the entry into Lime Grove for the cyclist is unattractive. Cyclists will need to keep right at the narrowing for the island for the crossing but no cycle lane will be apparent for them until after it. For vehicles in flow with them their intentions will be confusing at best. We suggest some more distance being placed here between the bus stops and the end of Lime Grove if possible. Otherwise, a clear indication in the carriageway of cyclists being able to turn right should be considered. Should protected space be possible here then we would advocate a better-protected junction perhaps with signals that utilise a bus stop bypass as a narrowing to help control traffic.

The start of Lime Grove then has two parallel loading bays, which seems to retain current levels of conflict if both are in use. The offset is a modest improvement but we note that Tesco have some parking of their own and are utilising pavement space to hold trolleys regularly. A solution with only one loading bay or loading bays only on one side would be far preferable and avoid a bottleneck to navigate immediately on entering a side street.

Otherwise the length of Lime Grove appears positive, though we would welcome some reminders of the contraflow nature when it is initially delivered to ensure local drivers and others are looking both ways until used to the scheme. It appears that there will be a reduction in road narrowing using kerbs and instead more use of trees, which without visualisation is hard to grasp but appears positive on a side street.

For the exit, again the route over onto the far Westbound side of Goldhawk Road is problematic, but perhaps the only solution as designed would be some indication cyclists can wait near the island if trying to make a two stage right turn. In the event of protected space this would need to be taken into account when delivering space through the nearby bus stops and in making the junction of Hammersmith Grove and Goldhawk Road provide cycle provision (where you are currently removing it heading Westbound).

We will consider this road heading west from the junction with the green and the gyratory

Junction heading East is wide which means exit is narrow. Cyclists having been given an advance stop line and feeder lane enter a bend with no cycle provision. Cyclists joining from the lanes through Shepherds Bush Green will be delivered into the road perpendicular to the direction of travel meaning they will only join if there are gaps. If possible in this scheme suggest narrowing the Westbound side where it widens toward the island to make more space possible for cycle lanes and avoid drivers speeding up too much on exit from this calmer space into the chaotic space of the gyratory. The approach at the Green end of Goldhawk Road seems more successful, but perhaps some thought should also be given to an early start for bikes here along the lines of that trialled at the Transport Research Laboratory, especially if it could enable easier access into the Green.

From Bush Theatre to Bush Market cycle lanes disappear on both sides of the street whilst space is taken from the road for pavement. Whilst we appreciate the need to enhance pedestrian space here the main gain for that appears to be in moving the bus stop and you are using some of this space to form loading bays. Given that this is set to be the commuter route into London in Ealing Council’s mini-holland bid we feel cycle provision must be continuous, at least in one direction if not the other (and like with bus lanes, the priority would seem to be London or East bound).

The cycle logo placed immediately before the bus stop at 15 Uxbridge Road will not assist with correct road positioning to navigate buses in the bus stop, but we presume that this is a feature of how a short cycle lane is designed. Given the frequency of buses on this road we don’t feel this is a great facility, at this section the road widens and it would be possible to provide safe space for cycling around these bus stops if they either used the main running lane or were offset fully.

The road narrowing outside the Parish Church of St Stephen and St Thomas seems particularly odd. Whilst this enables a simpler crossing, you are adding guardrail and this crossing appears to be the only reason that cycle lanes become discontinuous here. You are essentially interrupting your newly delivered cycle lane with trees. Whilst we are keen on green space being delivered we feel that the balance of the scheme is incorrect to deliver trees here rather than a direct cycle lane. Again, this is set to be a commuter route in Ealing Council’s mini-holland bid, and interruptions should be kept to a minimum.

This section again ends with a bus stop, and again cyclists are shown no path around it.

We will consider this road heading west from the junction with the green and the gyratory

We are happier with the entry into the Green from Goldhawk Road than Uxbridge Road, but again think some consideration should be given to early start lights should they pass the Transport Research Laboratory trials.

For the bus stops at the Eastern end of Goldhawk Road you are taking space from the road to provide pavement space, we would far prefer a solution which combined that with providing space for cyclists to pass the stop. In this section and Uxbridge Road the distance between stops is small, and we would suggest that if it is particularly troublesome to bypass both stops that the need for both stops is carefully assessed.

The turn into Pennard Road is more sensible than that into Lime Grove on Uxbridge Road, with the turn before a traffic island, and the waiting space being directly opposite the road to be turned into. Obviously in a scenario with protected lanes a more fully worked junction would be necessary.

If there is a section where a protected lane behind parking would work best it would appear to be the next section from 26 to 47 Goldhawk Road, where you are placing trees, loading and parking bays into the pavement. We are keen to remind you that the risk of car doors opening into the cycle lane is high, and wish to see it minimised as far as possible.

The cycle lanes again disappear through the crossing point from 47a to 51 Goldhawk Road. Is it absolutely necessary for them to go when markings for crossings appear, as your design makes it appear? There is clearly width to support the lanes. Separately this is the section where the risk from buses entering and leaving the nearby bus garage commences. It seems an interesting design choice to add a new signalled crossing in this location but not add facilities for it to assist buses entering and leaving the garage. Whilst the new crossing is close to the market it is offset from the bus stops and the underground station, where passengers regularly cross directly in the road and no facilities are provided even in this design.

The working of the cycle lanes around the bus stops just beyond the underground station looks a concern. In particular for buses terminating, changing crew or arriving in groups space for only two buses heading Westbound seems insufficient. Buses already head straight into their stop from the junction with Hammersmith Grove so we consider the alignment of lane markings optimistic. Again, experience elsewhere shows that a bus stop bypass is the safest arrangement for cyclists in such locations and we’d welcome designs that explored their use.

We then pass Richford Street, which strangely is the only one way entrance where cycling has not been added. We think it a good idea to permit cycling into this street, especially as it would permit cyclists to reach all the way down to Trussley Road avoiding the busier through route of Hammersmith Grove.

The junction with Hammersmith Grove itself is perplexing. You have gained a lot of extra space by removing the existing pedestrian pen in the midst of the road, yet this plan removes the cycle lane along the Westbound lane. The plans appear to indicate that the Westbound lanes have been widened and yet still the cycle lane has not been retained. Losing all cycle facilities into this junction is a mistake that you should not carry into the final design. Yet you are finding space for bays for parking, which appear to be replacing a bus lane that had hours of 7-10am and 4-7pm Mon-Sat. We consider safe space for cycling at a busy junction to be a higher priority than parking this close to a junction.

The design as a whole does not seem to have considered if the need for Hammersmith Grove to be used, as it is now, a 20mph through route with many vehicles using it to avoid gyratories at Shepherds Bush and Hammersmith Broadway is the most sensible option long term. The section of Goldhawk Road immediately prior is two lanes Westbound and three lanes Eastbound, which seems far too much given the reduced space ahead. What risk is there that extra traffic diverts into Hammersmith Grove given the calmed environment ahead? For pedestrians a crossing on the Western side of this junction would seem sensible and useful, of more priority than enabling vehicles turning right into Hammersmith Grove from Goldhawk Road. By contrast the turn out of Brackenbury Road is inaccessible to/from the eastbound lanes of Goldhawk Road, a clear calming intervention. We would again favour some exploration of low-level cycle lights and a cycle phase to permit cyclists to quickly enter Hammersmith Grove and carry on into Goldhawk Road heading East. Heading West, assuming cyclists can reach the advance stop line without a feeder lane a similar treatment would be of benefit. The risk of left hooks for cyclists in the left turn lane is high. We note that the Mayor’s Cycling Vision speaks of segregated lanes being used in such situations “where possible” (page 19), space would surely permit it here.

Thanks for your consultation, and we hope that we can work together to ensure that you deliver improvements to cycle safety for cyclists in the near future on this and other routes.

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We are the local branch of the London Cycle Campaign (LCC) for the London Borough of Hammersmith and Fulham. We also cover Shepherd's Bush but that's not part of the name of our borough, a fuller guide to where we cover is here.